Nigeria issues guidelines for new tax regime transition

Nigeria's Federal Government has issued comprehensive guidelines to manage the shift from its old tax laws to a new framework that began in 2026. The Federal Ministry of Finance released these directives on Thursday, aiming to provide clarity on handling tax obligations, audits, disputes, incentives, and filings that bridge the old and new systems.

The new tax regime, enacted through a package of reform laws, seeks to modernize revenue administration and boost compliance. According to the ministry, liabilities, audits, and investigations related to periods before the new regime's start will continue under the repealed laws. Similarly, tax returns for periods ending before January 1, 2026, will follow the old framework, while subsequent obligations fall under the new laws.

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The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.

These guidelines are designed to address practical transition issues and ensure consistent implementation across tax authorities. The reforms are built upon four key legislations: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act. The guidance also details how existing tax incentives and exemptions will be treated under the new system, assuring businesses that commitments made under previous laws will be honored until their expiration. However, new applications for incentives will be assessed under the new laws.

Minister of Finance Taiwo Oyedele stated the guidelines ensure a smooth migration without retrospective application of the new laws. He described the Tax Acts 2025 as a significant milestone, providing certainty for both taxpayers and administrators. The framework emphasizes clarity, fairness, and administrative certainty, marking another step in Nigeria's broader tax reform program aimed at creating a more efficient, transparent, and growth-oriented revenue system.

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Mr Oyedele described the Tax Acts 2025 as a significant milestone in the government’s fiscal reform agenda, noting that the transition framework would provide certainty for taxpayers and tax administrators alike.